Final Submission : BC Broadband Association (Intervenor 275)

Document Name: 2015-134.224004.2613157.Final Submission (1k0bp01!).html

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Final Submission : BC Broadband Association (Intervenor 275)

Document Name: 2015-134.224004.2613156.Final Submission (1k0b_01!).pdf
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May 25, 2016
**** May-Cuconato
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, ON, *** ***

Re: Final comments to Telecom Notice of Consultation CRTC 2015-134 - Review of basic telecommunications services (File No. 8663-C12-201503186) **** Ms. May-Cuconato:

1. At the outset of this proceeding, the Commission has asked about:

 Canadians’ connectivity needs;
 Whether internet is a basic service;

 Whether broadband should be treated like phone service; and  How the Commission can best support Canadians’ access to broadband.

2. Also, during the course of this proceeding, the Commission asked whether Canada needs a national broadband strategy, and what that national broadband strategy might look like.

BCBA Position

3. The British Columbia Broadband Association’s (BCBA) position is that internet connectivity is indeed crucial for Canadians’ engagement in the digital economy, and that 5 Mbps down / 1 Mbps up is an adequate benchmark speed at the moment, and should be revised as the digital ecosystem changes with time.

4. Our support for this speed target reflects both our experience with our customer’s choices, and our preference for a target that can be delivered to most, if not all, Canadians in the medium term.

5. Most respondents to the proceeding agreed that broadband is an essential service, and the BCBA agrees with this assessment.

6. The BCBA contends that the CRTC should not enact any subsidy mechanism modeled after the existing basic telephone service regime to support a basic service objective for broadband. Rather, the Commission should support targeted funding at all levels of 2 | P a g e

government, such as the Digital Canada 150 program and many other successful provincial and local government programs. These initiatives have brought connectivity to most Canadian households, and continue to reach under-served households effectively and economically.

7. The development of a national broadband strategy will help direct programming (policy, funding, and otherwise), and ensure consistency across programs. This clear direction and consistency will promote effective deployment of funds and resources in delivering a basic service objective to all Canadians.

A National Broadband Strategy

8. The BCBA supports the Commission’s call for a national broadband strategy in Canada, and we would like to take this opportunity to outline some elements that we see as integral to such a strategy.

9. A national broadband strategy would have the following elements. Any of these elements may evolve as technology, demographics, and the telecommunications marketplace changes, and ongoing evaluation of these elements would be an important part of the strategy.

a. A description of how a basic service level (or levels) is determined;

b. A mechanism to identify populations with lagging access to basic service;

c. A clear understanding of the barriers to access faced by these populations;

d. A financing mechanism; and
e. Other policy mechanisms
Quantifying Basic Service

10. A basic service level could be determined in a number of ways – by following the lead of other countries, by evaluating the connectivity requirements of various applications, or by tracking market data.

11. The CRTC is well-positioned to gather market data from a variety of providers. The CRTC currently collects a wide variety of information regarding carriers’ operations, and is trusted by carriers to gather confidential data. Information regarding the distribution of customer choice across packages of varying speeds and prices could be used to inform an analysis of how Canadians evaluate their own basic needs.

12. A survey of basic service objectives from other countries is an important part of such an analysis, but the CRTC should be cognisant of varying market conditions (such as population density), and the choice of targets that are defined by political, rather than practical, expedients.

Defining Rural Populations

13. In discussing the identification of populations with lagging access, the BCBA will confine our comments to the question of rural and remote populations. We recognize that other 3 | P a g e

barriers to access, such as affordability and accessibility to individuals with disabilities, may be linked with and compounded by rural locations. The BCBA is best positioned to address rural connectivity and we address this in isolation below.

14. The Commission has heard from many Canadians who have been left out of the digital world – positioned just past the end of the land-line infrastructure, behind hills that block wireless signals, or in remote communities that have extremely constrained backhaul connections to the Internet.

15. There are many Canadians who choose to live in relative isolation – far from paved roads, electricity, and broadband. Satellite services provide adequate basic digital connectivity to these isolated households.

16. We should make a distinction between those individual households that are situated in the most un-serviceable locations by choice, and those communities that should have access to the interconnected world, but do not. Disconnection from the digital economy should not be imposed on communities – however small – because they are rural or remote.

17. The choice of an agricultural or rural lifestyle should not necessarily preclude access to education, social services, entrepreneurship, or civic engagement.

18. In identifying the populations and communities that should have broadband access, but do not, a national broadband strategy must engage all levels of government, including provincial and local governments. These lower levels of government have great familiarity with the extent of broadband reach in their communities, and often have a strong understanding of the barriers to access.

19. Across Canada, various governments have undertaken numerous rural connectivity funding programs, with varying levels of success. Each of these programs has advantages, and those advantages of working with local levels of government should not be lost. A federal program alone will struggle to succeed without the engagement of provincial, regional, and local governments.

Barriers to Access

20. Bringing broadband to rural communities is a challenge that is primarily financial. Access to spectrum is also a barrier for many rural service providers, and this is discussed under “Other Policy Mechanisms” below. In this section, we look at the nature of the costs faced by rural carriers.

21. When BCBA members expand into rural and remote communities, we face high costs. In bringing service to rural areas, we install infrastructure, such as communications towers, at sites that are off-grid and off-road. We maintain infrastructure that is far from dispatch centres, and more time-consuming to repair.

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22. It is worth noting that real estate is one of the largest costs we face in deploying a network.

23. Providing connectivity to rural areas requires substantial capital investment. To reduce operating costs, we invest in robust and rugged systems that will withstand harsh environments and require minimal maintenance. We engage with community groups to gain market knowledge, and we partner with local contractors to build and maintain our infrastructure. We leverage funding from all levels of government to support these projects.

Funding Mechanisms

24. Targeted capital funding initiatives from government can provide an ISP with a viable business case to service a rural or remote community. These funding programs are the best way for governments to promote the delivery of reliable and sustainable services in rural areas, and to ensure that these services can remain competitively priced and technologically relevant in the long term.

25. The subsidy regime for basic telephone service was appropriate in an environment where only one company (the ILEC) had the ability to service an area. However, in the broadband market, multiple companies and technologies are able to service any community. In this context, an ongoing subsidy mechanism can only harm Canadians’ access to competitive services.

26. Once services are established at high capital cost, ISPs are reluctant to abandon a market.

We continue to invest in service upgrades to these communities.

27. **** companies, based in rural areas, are at the forefront of bringing urban-grade connectivity to rural Canada. Our members are able to target small communities efficiently and effectively.

28. Our members are an important part of the local connected ecosystem – with local knowledge and expertise, trained technical staff based in small communities, and ongoing engagement in the communities we serve through community initiatives and local governments.

29. Unfortunately, many small rural companies struggle to access funding programs launched by the federal government due to the heavy administrative burden imposed by federal programs. For this reason, local and provincial governments should be part of the national broadband strategy – to enable small rural carriers to participate so that the digital divide is addressed efficiently, effectively, and in a way that makes rural communities stronger.

Other Policy Mechanisms

30. In addition to financial support, other policy mechanisms have the potential to contribute to bridging the digital divide. Spectrum management is one example of an area of policymaking that has a large impact on rural broadband services.

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31. The Canadian Association of Wireless Internet Service Providers (CanWISP) group raised the point that the availability of spectrum has an impact on the ability of ISPs to provide services to rural Canadians. The BCBA strongly agrees. Though outside of the scope of the current proceeding, spectrum availability should be a part of a national broadband strategy.

32. Fixed wireless deployments are the most effective way to bring connectivity to many rural areas, and spectrum is an integral part of these deployments.

33. The spectrum allocation mechanisms used by Innovation, Science, and Economic Development Canada (ISED) have, to date, been focused on distributing spectrum to national mobile carriers. This focus has resulted in the under-utilization of spectrum in rural areas.

34. The adoption of policy goals to see more spectrum serving rural broadband customers should be an important part of a national broadband strategy. Such a policy goal would inform spectrum allocation decisions and distribution (auction) mechanisms in ways that would enable smaller companies to access more spectrums.

35. In the hands of the smaller, rural service providers, spectrum can be leveraged to bring reliable, fast, and future-proof connectivity to rural communities.

Closing

36. We believe that ISED is well-positioned to administer a national broadband strategy. ISED has successfully delivered two national programs, and is in a position to address spectrum policy as well as manage funding programs.

37. We thank the Commission for engaging with the important questions surrounding broadband availability for Canadians. We look forward to working with the Government of Canada, other levels of government, our industry partners, and community organizations to bridge the digital divide in Canada.

Sincerely,
Bob ****
President - BCBA
******@***.com
*** End of Document ***